California Environmental Protection Agency
Air Resources Board
Potential Changes to the PERP Regulation and Portable Engine ATCM
November 10, 2016Sacramento
Questions/Comments During Workshop
• We want as much feedback today as possible
• Please hold all questions until after presentation
• For those viewing remotely, you may submit questions via email at [email protected]
2
Background
• PERP Regulation effective September 17, 1997
• Voluntary program for registration– Allows for Statewide operation of engines & eq. units
– Districts retain permit authority
– ARB sets requirements, Local Districts enforce
• Approximately 39,000 units– 30,500 engines
– 4,500 equipment units
– 4,000 TSE3
Background (con’t)
• Portable ATCM effective March 11, 2005
• Part of the Diesel Risk Reduction Plan– New engine standards (Tier 4, etc.)
– Cleaner diesel fuel (15 ppm)
– Replacement of older engines
• PM Reduction Strategies– Tier 0 phase out
– Permit eligibility
– Fleet Average4
Current ATCM Requirements
• Tier 0 engines gone since 2011–Except emergency & low use (2017)
• Limited eligibility for PERP and local permits
• Fleet Average Standards (PM) currently in effect
5
Fleet Standard Compliance Date
Engines <175 hp
(g/bhp-hr)
Engines 175 to 750 hp(g/bhp-hr)
Engines >750 hp
(g/bhp-hr)
1/1/13 0.3 0.15 0.251/1/17 0.18 0.08 0.081/1/20 0.04 0.02 0.02
Opening the Portable ATCM
• Compliance with future fleet requirements projected to be very difficult
– ATCM adopted 12 years ago (before T4 was created)
– Delay in availability and high cost of Tier 4 engines
– Abundance of flex engines (>15% of PERP inventory)
– Retrofits not getting to portable sector (only 7 engines total)
• Necessary to revise fleet requirements due to the lack of needed technology
6
Amendment Process So Far• ARB staff crafted initial regulatory concepts
• Public workshops held in March, June, and September 2016
• Meetings with CAPCOA and stakeholder workgroup to further develop concepts
7
8
Emission Reduction Strategies
Proposed ATCM Changes
Tier phase out for all fleets (old proposal):
Fleet defined as all engines operated in California owned by a single entity, except military installations Small fleets are 750 total bhp or less, large fleets are >750 total bhp
Pre-2007 on-highway engines will be treated as Tier 3 for phase out
EngineCertification
Engines rated 50 to 750 bhp Enginesrated
>750 bhpLarge Fleet Small Fleet
Tier 1 1/1/2020 1/1/2020 1/1/2022
Tier 2 1/1/2023 1/1/2025 1/1/2027
Tier 3 built prior to 1/1/2009
1/1/2026 1/1/2028 NA
Tier 3 built on or after 1/1/2009
1/1/2028 1/1/2030 NA
Tier 1, 2, and 3 flexibility engines
December 31 of the year 18 years after the date of manufacture
9
Valley has the most challenging PM2.5 air quality in the Nation
Comprehensive approach of NOx and PM2.5 reductions needed to meet PM2.5 standard
Board heard from advocates that Valley PM2.5 SIP needed to be strengthened
Board directed staff to investigate ways to achieve more emission reductions
New approach in Portable Engine ATCM allows opportunity for further NOx and PM2.5 reductions.
San Joaquin Valley Air Quality Issues
10
Emission Reduction Strategies
Proposed ATCM Changes
Tier phase out for all fleets (new proposal):
Fleet defined as all engines operated in California owned by a single entity, except military installations Small fleets are 750 total bhp or less, large fleets are >750 total bhp
Pre-2007 on-highway engines will be treated as Tier 3 for phase out
EngineCertification
Engines rated 50 to 750 bhp Enginesrated
>750 bhpLarge Fleet Small Fleet
Tier 1 1/1/2020 1/1/2020 1/1/2022
Tier 2 built prior to 1/1/2009
1/1/2022 1/1/2023 1/1/2025
Tier 2 built on or after 1/1/2009 (>750 bhp)
NA NA 1/1/2027
Tier 3 built prior to 1/1/2009
1/1/2025 1/1/2027 NA
Tier 3 built on or after 1/1/2009
1/1/2027 1/1/2029 NA
Tier 1, 2, and 3 flexibility engines
December 31 of the year 17 years after the date of manufacture
11
Large fleets have fleet average option:
Criteria for large fleets to use fleet average All engines in fleet subject to ATCM must be registered in PERP Must submit a request by 2019 to use option If fleet has unpermitted engines after 2019, out of fleet average
Retrofitted engines exempt from phase-out requirements Must have verified Level 3 diesel particulate filter Still included in Fleet Average option for large fleets
Proposed ATCM Changes
Compliance Date
Fleet PM Standard (g/bhp-hr)
1/1/20 0.10
1/1/23 0.06
1/1/27 0.03
12
Used PERP data from 2011-2016Assumed fleets will keep a constant average ageReceived about 3,500 surveys
Average 850 hours operated annually Varies among industries (especially rental vs. non-rental)
Average load factor of 31% across multiple engine uses and industries.
Model simulates fleet turnover based on compliance with standards and constant average age.
Inventory Methods
13
Emissions Inventory Statewide
0
0.2
0.4
0.6
0.8
1
1.2
1.4PM
(T
PD
)
PM (TPD)
No Rule
Current ATCM
Old Proposal 67% PO33% FA
New Proposal 67% PO33% FA
0
5
10
15
20
25
30
35
NO
x (T
PD
)
NOx (TPD)
No Rule
Current ATCM
Old Proposal 67% PO 33%FA
New Proposal 67% PO33% FA
14
Emissions Inventory Statewide
15
Cost CurvesStaff collected cost data for about 250 pieces of used equipment and cost data from engine manufacturers on Tier 4 final.
$-
$100.00
$200.00
$300.00
$400.00
$500.00
$600.00
$700.00
$800.00
0 5 10 15 20 25 30 35
$/h
p
Age
Cost Curve
Under 175 Data
Over 175 Data
Modeled Costs Under 175
Modeled Cost Over 175
16
Estimated Annual Cost
$0
$100
$200
$300
$400
$500
$600
$700
$800
$900
2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032
Million
s
No Rule
Current ATCM
Old Proposal 67%PO 33% FA
New Proposal 67%PO 33% FA
Year
Reductions from Old Proposal Relative to No Rule
Reductions from New Proposal Relative to No Rule
Difference Between Proposals
$ PM (TPD) $ PM (TPD) $ PM (TPD)
2019 $37,134,519 0.029 $37,134,519 0.029 $0 0.000
2020 $167,010,671 0.122 $167,010,671 0.122 $0 0.000
2021 ‐$6,025,296 0.084 ‐$6,025,296 0.084 $0 0.000
2022 $118,766,627 0.145 $194,791,731 0.184 $76,025,104 0.039
2023 $132,646,680 0.174 $57,913,324 0.171 ‐$74,733,355 ‐0.002
2024 $9,735,666 0.140 $12,278,002 0.142 $2,542,335 0.002
2025 $72,616,331 0.114 $212,008,857 0.176 $139,392,526 0.062
2026 $112,026,776 0.126 ‐$14,256,189 0.147 ‐$126,282,966 0.021
2027 $192,034,239 0.158 $223,578,776 0.179 $31,544,537 0.020
2028 $80,865,009 0.152 ‐$20,246,117 0.146 ‐$101,111,127 ‐0.006
2029 ‐$32,651,049 0.119 $3,343,264 0.119 $35,994,313 0.000
17
Cost of PM Reductions(Old Proposal – New Proposal)
18
Cost of Ancillary NOx Benefits (Old Proposal – New Proposal)
Year
Benefits from Old Proposal Relative to No Rule
Benefits from New Proposal Relative to No Rule
Difference Between Proposals
$ NOx (TPD) $ NOx (TPD) $ NOx (TPD)
2019 $37,134,519 0.806 $37,134,519 0.806 $0 0.000
2020 $167,010,671 2.919 $167,010,671 2.919 $0 0.000
2021 ‐$6,025,296 2.000 ‐$6,025,296 2.000 $0 0.000
2022 $118,766,627 3.188 $194,791,731 4.127 $76,025,104 0.939
2023 $132,646,680 3.892 $57,913,324 3.829 ‐$74,733,355 ‐0.063
2024 $9,735,666 3.109 $12,278,002 3.158 $2,542,335 0.049
2025 $72,616,331 2.550 $212,008,857 3.754 $139,392,526 1.204
2026 $112,026,776 2.865 ‐$14,256,189 3.089 ‐$126,282,966 0.224
2027 $192,034,239 3.084 $223,578,776 3.519 $31,544,537 0.435
2028 $80,865,009 2.871 ‐$20,246,117 2.750 ‐$101,111,127 ‐0.121
2029 ‐$32,651,049 2.058 $3,343,264 2.060 $35,994,313 0.002
19
Emissions Inventory - SJV
0
0.05
0.1
0.15
0.2
0.25
PM
(T
PD
)PM (TPD) - SJV
No Rule
Current ATCM
Old Proposal 67% PO 33% FA
New Proposal 67% PO 33% FA
0
1
2
3
4
5
6
NO
x (T
PD
)
NOx (TPD) - SJV
No Rule
Current ATCM
Old Proposal 67% PO 33% FA
New Proposal 67% PO 33% FA
NOx difference of 0.26 TPD in 2025
PM difference of 0.014 TPD in 2025
0
2
4
6
8
10
12
14
NO
x (T
PD
)
NOx (TPD) - SC
No Rule
Current ATCM
Old Proposal 67%PO 33% FA
New Proposal 67%PO 33% FA
0
0.1
0.2
0.3
0.4
0.5
0.6
PM
(TPD
_
PM (TPD) - SC
No Rule
Current ATCM
Old Proposal 67%PO 33% FA
New Proposal 67%PO 33% FA
20
Emissions Inventory - SC
NOx difference of 0.54 TPD in 2025
PM difference of 0.025 TPD in 2025
21
Low-use and emergency-use engines exempt from fleet requirements Low-use engines increased to 200 hr/yr Must designate Tier 1 & 2 engines 6 months prior to phase-out Can’t convert Tier 1 & 2 to regular use unless exceed limitation
Benefit for fleets in compliance with 2017 fleet standards Separated by size category (<175, 175 - 750, >750) Two extra years for phase-out OR Double count T4 in fleet average for first two dates
Benefit for removing Tier 1 or Tier 2 engines early Must be removed from service in California Remove a Tier 1 by 1/1/2019 or Tier 2 by 1/1/2021 Extra 1 year for a specific Tier 3 (including flex) on phase-out
schedule only
Proposed ATCM Changes
22
Prohibition of sale Districts may take action against sellers of non-compliant engines The sale of engines for resale out of California not prohibited Tier 0 engine sales always prohibited Tier 1, 2 and 3 engine sales prohibited after phase-out dates Tier 4 interim and final engine sales never prohibited
Disclosure of applicability All legal engine sales must have a written disclosure to buyer Consistent with other existing diesel regulations May allow for combined disclosure for multiple regulations
“When operated in California, any portable diesel engine may be subject to the California Air Resources Board Airborne Toxic Control Measure For Diesel Particulate Matter From Portable Engines Rated At 50 Horsepower And Greater. It therefore could be subject to retrofit or accelerated turnover requirements to reduce emissions of air pollutants. For more information, please visit the California Air Resources Board website at http://www.arb.ca.gov/portable/portable.htm”
Proposed ATCM Changes
23
Agricultural use definition and exemption Consistent with Stationary Engine ATCM Forest operations and first processing subject to Portable ATCM
Two-engine vehicle definition and exemption Subject to Off-Road Vehicle Regulation
Other exemptions for certain equipment Portable engines on commercial harborcraft Engines operated exclusively during emergency event
Add definition for replacement engines Included in the ATCM fleet requirements
Proposed ATCM Changes
24
Eligibility for permit/registration for flexibility engines Only recent tiers eligible → no Tier 2 ≤750 bhp or any Tier 1
Districts may permit lower tiers Currently, may not permit after January 1, 2017 Must show California residency for Tier 1, 2, and 3
Updated recordkeeping and reporting requirements Updated ATCM compliance statement required for large fleets
in fleet average when adding lower tiers or removing Tier 4→ equipment dealers and rental businesses exempt
Annual report for low-use engines Must keep records for each emergency (nature and date)
Remove obsolete language Tier 0 extension SCR provisions
Proposed ATCM Changes
25
Definitions Specific categories will be listed as PEPS Replace “mechanical breakdown” with “engine failure” Remote location is >½ mile from any business, residence, school, etc.
Eligibility for initial registration Agricultural use not eligible, except owned by a rental business Resident engines permitted by local air district if fleet is using FA Auxiliary engine on 2-engine vehicles subject to off-road Align with eligibility requirements in ATCM
Application processing Currently must Issue or deny registrations 90 days from receipt date Change issuance to 90 days from date application deemed complete
and keep denial at 90 days from receipt
Temporary registration Only for cleanest engines - Tier 4 final Certificate expires in 3 months
Proposed PERP Changes
26
Clarification on when PERP is invalid Nuisance already listed Moved generator prohibitions in 2451 to this section Qualify as part of stationary source determined by District Replacement of stationary engine when limits have been reached Recurring use of equipment unit and associated engine
• Must be onsite for more than 30 days for more than 2 years, or • Located onsite for >24 hours and occurs more than twice in one year• Engine only equipment is not prohibited
Allowable use of registered generators Electrical upgrade operations expanded to 90 days Maintenance and repair to include stationary generators Engine failure of stationary backup generator
District must give approval District notified by stationary permit holder within 72 hours Replacement engine must have same or cleaner emissions Replacement engine must comply with existing stationary permit Operation not to exceed 180 days, unless district grants approval
Proposed PERP Changes
27
Project review by non-attainment districts Projects using more than 2,500 portable horsepower must notify Districts may perform AQIA and mitigate if exceeds AAQS Projects with only Tier 4 and projects in remote locations exempt
Rental requirements Rental agreement must be readily available, not onsite Remove the notification requirement for >9 month rentals Records may be kept by company ID with cross reference
District reporting Districts must only submit annual report if not sending all
inspection reports via online DMS Annual report only to include inspections for PERP Must specify registration number for each inspection
Proposed PERP Changes
28
Identical Replacement Notification extended from 5 days to 30 days Limited to engines compliant with phase-out schedule Only affects non-registered engines
Change of ownership restriction No lower tiers within 6 months prior to small fleet phase out Prevent movement of older engines between fleets
Low-use designation for Tier 3 engines Must be submitted in January Aligns with annual report for hours
Reporting Submit hour meter readings on all engines at renewal
Proposed PERP Changes
29
Program Fee Increase Fees must cover cost of program implementation* Fees last adjusted in 2004 (ARB) and 2006 (districts) ARB fees increase at CPI + 20% and District fees at CPI
Proposed PERP Changes
Initial RegistrationCost Type PERP Regulation
CostPERP Amendment Cost
Change in Cost
ARB Fee $270 $395 $125 District Fee $345 $405 $60 Placard Fee $5 $5 $0 Total for New Registration $620 $805 $185
Registration RenewalCost Type PERP Regulation
CostPERP Amendment Cost
Change in Cost
ARB Fee $225 $330 $105 District Fee $345 $405 $60 Placard Fee $5 $5 $0 Total for Renewal $575 $740 $165
*Health & Safety Code, §41752, subd. (d)
30
Fee Collection Currently fees are sent with application forms (except renewal) Delays registration issuance due to incomplete applications Currently examining a change to how program fees are submitted
Multiple Engine Inspection Discount Districts may send bill for inspection fee difference Fleets that misuse discount will be prevented from future use
Remove obsolete Tier 0 engine language Tier 0 extension for spark-ignition engines Emission limits
Proposed PERP Changes
31
Tier 4 engine feasibility issues Multi-divisional team of ARB staff investigated this matter with
the following results: Team found high-idle, low-load engines which required frequent
DPF cleaning Team worked with manufacturer to identify cause of frequent pluggingManufacturer worked with CARB certification staff to make changes,
and no subsequent issues for >1,400 hours since change ARB team will work with manufacturers to solve issues as they arise
Engines operating in hazardous areas ARB will work with EPA on this matter May become ineligible for PERP, districts would permit
Tier phase-out enforcement Districts need to be able to readily identify tiers in the field Considering methods for field identification and enforcement
Other Issues
Next Steps
• Update draft regulatory language
• Staff Report including proposed regulations available early 2017
• Board hearing April 2017
32
For more information: www.arb.ca.gov/portable/portable.htm
Sign up for the portable listserv:www.arb.ca.gov/listserv/listserv_ind.php?listname=portable
Send questions or comments via email:[email protected]
33
